Joint Press Info – Environmental footprint methodology: not for us state consumers and manufacturers

The suggested methodology – according to ACEA, ANEC and Orgalime – does not represent a reliable tool for creating demand for ‘better and greener products’” in the EU, while it risks exposing companies to unfair competition and market distortion as consumers would base their buying decisions on misleading information.

In the light of ANEC’s longstanding research on LCA suitability and environment-related standardisation, as well as the automotive and engineering industry’s long and solid experience in applying LCA and related methodologies to products and processes as an internal evaluation methodology, the associations have detailed the limits of the LCA-based methodology.

They highlight it creates unneeded risk of disruption to the internal market for products and allows room for unfair competition, while providing doubtful benefits, if any, for consumers or for industry. Orgalime’s President Sandro Bonomi stated: “If used in support of regulation, the methodology would undermine the Commission’s wider Industrial Policy agenda, hampering policy makers from acting on a sound basis for comparing products. Neither would it help to stimulate demand for ‘better and greener’ products. And finally, it would also cause severe difficulties for enforcement and market surveillance”.

Although the benefits of Life Cycle Assessment (LCA) as an internal instrument for manufacturers are not in doubt, its limits and shortcomings are evident:

• The precision of the results provided by LCAs is limited by data constraints and LCA results can provide only a partial picture at best.
• LCA results are dependent on subjective choices at the level of inputs into the model.
• LCAs are complex and costly, making them excessively difficult for SMEs to make and to afford.
• LCAs do not allow consumers to make informed product comparisons or choices.

ACEA Secretary General, Ivan Hodac added: “LCA ignores the complexity and diversity of products and supply chains: the current ‘one size fits all approach’ of the suggested methodology overlooks the diversity and variety of the different products made available to consumers. Only the making of an engine, for example, consists of a multitude of different components, parts and materials that are sourced in complex, multi-layer, global supply chains”. ANEC Secretary General, Stephen Russell commented, “Sound environmental assessments require a mix of tools, taking into account the strengths and weaknesses of each.

The right indicators for the right products and the right organisations need to be identified using a broad range of assessment methods, with the decision made at the political level, after consultation of all interested stakeholders”. ACEA, ANEC and Orgalime confirm their assessment that the suggested methodologies cannot provide a reliable and trustworthy base for creating demand for ‘better, greener’ products through correctly informed consumer choices. It is our joint recommendation to the Commission to pause and rethink its planned Communication, and the environmental footprint methodology in particular. The three associations advocate the use of a mix of policy tools, and a sector-by-sector approach, to achieve the intended results of the Commission´s PEF and LCA approach while respecting the objectives of the EU’s Industrial Policy Communication and the related Council Conclusions.